News & Analysis as of

Internal Revenue Service Corporate Taxes Compliance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Mayer Brown

Changes to IRS Examinations of Large Corporate Taxpayers: A Sea Change or Whistling in the Wind?

Mayer Brown on

On July 23, 2025, the IRS issued guidance on audits of large corporate taxpayers. This guidance falls squarely in line with previous IRS statements at conferences, as well as its prior guidance about making examinations more...more

McDermott Will & Schulte

Treasury Finalizes DPL Rules, Extends Transitional DCL Relief for Pillar Two Taxes

Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more

Littler

IRS Ruling Clarifies Employment Tax Implications of Paid Family and Medical Leave Programs

Littler on

The IRS’s recently released Revenue Ruling 2025-4 provides significant guidance on the employment tax treatment of contributions to and benefits paid under state paid family and medical leave (PFML) programs. This has been an...more

Skadden, Arps, Slate, Meagher & Flom LLP

New Proposed Regulations Aim To Overhaul Tax-Free Spin-Off Rules

On January 16, 2025, the Treasury Department (Treasury) and Internal Revenue Service (IRS) published new proposed regulations related to tax-free spin-offs and split-offs (collectively, spin-offs) and other corporate...more

Crunched Credit

The Administrative Illuminati in Pursuit of Command and Control (Or the Unmentionable in Hot Pursuit of the Inedible with...

Crunched Credit on

The way we regulate rarely works terribly well for the regulator or the regulated.  Yet, we keep doing it the same way…a subspecies of insanity to be sure.   As an example, has anyone out there in CRE land taken a gander at...more

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Morgan Lewis

Large Corporate Compliance and Data Analytics: Have You Analyzed Your Own Data Recently?

Morgan Lewis on

The Internal Revenue Service will be implementing a new program using data analytics to select which large corporate taxpayers to audit. The program will identify which corporate tax returns show the highest compliance risk...more

Rosenberg Martin Greenberg LLP

What are some of the monetary penalties and other consequences of failing to properly report my foreign real estate and other...

Depending upon how foreign real estate is owned and/or controlled, a number of different tax reporting regimes may be implicated.  Each of these has its own corresponding penalties and generally applies to United States...more

Goulston & Storrs PC

New Trade Act Hikes Penalties for Information Return Failures

Goulston & Storrs PC on

The newly-enacted Trade Preference Extension Act boosts the penalties for failing to provide accurate information returns to the IRS and payees – such as Forms W-2, 1098, and 1099, as well as Forms 1095-B and 1094-B. The...more

King & Spalding

IRS Clarifies "Substantial Risk of Forfeiture"

King & Spalding on

The Internal Revenue Service ("IRS") recently issued final regulations clarifying whether a substantial risk of forfeiture exists in connection with a transfer of property, such as restricted stock, in connection with the...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Large Business and International Division Increasingly Looks to Chief Counsel's Office to Advance Initiatives"

The Internal Revenue Service Large Business and International Division (LB&I) administers United States tax law for corporations, partnerships and individuals with assets greater than $10 million. These taxpayers typically...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Releases Final and Proposed Regulations Regarding Dividend Equivalent Payments to Foreigners"

As part of 2010 legislation, Congress enacted section 871(m) of the Internal Revenue Code, which provides that payments made to foreign persons under specified notional principal contracts (“Specified NPCs”), securities...more

Orrick, Herrington & Sutcliffe LLP

Post-Issuance Tax Compliance and Continuing Disclosure Responsibilities for Issuers and Borrowers of Tax-Exempt Bonds

Chapter One: Introduction: Why Post-Issuance Compliance? Over the past few years, the tax-exempt bond market has been under heightened scrutiny by various regulators, including the Internal Revenue Service...more

Troutman Pepper

IRS Rules That A Partially Tax-Free Transaction Qualifies As ‘Covered Transaction’ For Purposes Of The Transaction Cost...

Troutman Pepper on

The Internal Revenue Service (the Service) recently released Priv. Ltr. Rul. 2013-19-009, which interprets the transaction cost regulations of Treas. Reg. §1.263(a)-5....more

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